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June 16, 1982) in the amount of $807.38. Respondent did not
credit petitioners’ 1979 account with interest for the period
June 16 through June 28, 1982. On June 13, 1983, when respondent
refunded to petitioners the overpayment petitioners claimed on
their 1982 tax return, respondent did not credit petitioners’
1982 account with interest for the period June 1 through June 13,
1983.
B. The Tax Court Proceeding and Surrounding Circumstances
On October 15, 1986, respondent sent to petitioners a notice
of deficiency, in which respondent made adjustments on account of
TEA items and determined deficiencies and additions to tax as
shown in table 1.
Table 1
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6659
1978 $14,607 $730 –- $4,382
1979 8,208 410 -- 2,462
1981 9,537 477 1 2,861
1982 8,129 406 2 2,439
1 50 percent of the interest due on $9,537.
2 50 percent of the interest due on $8,129.
Respondent also determined that petitioners’ deficiencies
are subject to an increased rate of interest under section
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